OSHA is at the Door, Now What!?
by Sally McKenzie CEO
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“Doctor, there’s an OSHA inspector here to see you.” Now that’s a line that you just never want to hear. But if your business employee quietly calls you away from your patient and delivers that urgent message, will you be prepared?
Certainly, random inspections of dental practices are not commonplace, but they do happen and typically they are precipitated by a complaint to the Occupational Safety and Health Administration from either a patient or an employee. Who would do such a thing? You may never know. Those who complain to OSHA are not required to identify themselves and can remain anonymous. The anonymous complaints usually prompt a letter and require the dentist to reply within five days with supporting documentation proving the allegation isn’t true. Whether the complaint is valid or not is irrelevant. It’s a complaint and OSHA will check it out and expect you to respond.
If the individual, filing the grievance gives their name, OSHA will conduct an onsite inspection. And if an inspector is in your dental practice, they will take the time and effort necessary to carefully examine the safety systems of the entire practice in excruciating detail making it far more likely that a violation will be discovered.
So how do you prepare for this not-so-welcome visit? Don’t open the door. In other words, take steps to ensure that OSHA doesn’t have cause to visit your office, starting with a strong internal communication system. The goal is to ensure that in your practice employees feel completely at ease bringing matters to your attention that they feel could be potentially harmful.
Always listen to employee concerns and either take action on the issue or thoroughly explain to the staff member why they do not need to worry. But don’t dismiss them or imply that they are foolish in raising the issue with you. You want them to ask questions and make you aware of circumstances that may be completely safe but could be perceived as problematic. Keep in mind that if one employee is raising the issue, it’s likely been discussed among the staff at large and perhaps even in front of patients.
Oftentimes, it is how well a doctor handles the internal communication with employees and/or patients that dictates whether they find themselves having to defend their practices against an OSHA complaint.
In addition to open communication systems, make sure you have clearly established compliance protocols in place in your office as well. For example, every practice should have a written Hazard Communication Program on file and available to all employees that includes the following:
- A list of all hazardous chemicals present in the practice.
- A description of the labeling system used in the office to warn against chemical hazards.
- An explanation of the procedures for obtaining Material Safety Data Sheets (MSDS).
- Documentation of employee training.
In addition, practices must comply with the Bloodborne Pathogens standard. It requires:
- A written exposure plan, which is updated annually.
- Identification of those employees covered by the standard.
- A list of job classifications.
- Methods of compliance.
- How specific wastes are regulated.
- Documentation that Hepatitis-B vaccinations have been received by all employees.
- Post exposure records on any employee who has had an incident, requirements for reporting exposure incidents, requirements for maintaining medical records on employees with occupational exposure.
- Annual staff training covering several issues regarding bloodborne pathogens.
Get the team involved in compliance. Appoint an OSHA compliance point person. This employee is your safety officer or compliance officer and should be very detail-oriented and able to manage the practice’s OSHA program. She/he knows where all OSHA documentation and records are located. She/he makes sure the practice has OSHA illness/injury logs available and they are up-to-date. This person ensures that the required safety programs are in place and documentation proving that required safety training has taken place and emergency protocols are in place and on file. She/he manages the OSHA manual and ensures that it is current. And she/he verifies that clinical employees have received the required Hepatitis B series and maintains the necessary records.
The doctor should periodically review the steps the employee has taken and confirm that necessary records, logs, and other documentation are in place. see
Next week, Do’s and Don’t’s when the inspector comes to call.
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